4.6: Financial Transparency
Incorporate the three principles defined by OMB: Transparency – how Federal funds are spent; Participation – broad stakeholder
interaction on establishing openness; and Collaboration – inclusive interaction to determine the most useful data
Other Information:
OMB has provided guidance for the development of a Data Quality framework for Federal Spending data. Federal spending data
includes financial and associated performance and programmatic data disseminated to the public, including data currently reported
in USASpending.gov. DOI’s plan will incorporate the three principles defined by OMB: Transparency – how Federal funds are
spent; Participation – broad stakeholder interaction on establishing openness; and Collaboration – inclusive interaction to
determine the most useful data. The data quality plan consists of two sections including: Implementation of the quality framework
and USASpending.gov data quality. The plan outlines the framework for data quality that will ensure an internal controls environment
over the preparation and dissemination of financial data and organizational structure, policies, processes and systems to
achieve: Effectiveness and efficiency of the operations producing and disseminating financial information; Reliability of
the financial information reported; and Compliance with laws and regulations. DOI’s Data Quality plan will focus on the reliability
of reported data, and ensure compliance with appropriate regulations. The key assertions that management will be making for
federal spending data may ensure that reported data is correct and reported timely. Not all assertions will apply to all data
sets and judgment is required to develop appropriate test plans. The assertions are defined as: 1. Existence (Validity): Only
valid or authorized data is reported (i.e., no invalid data). 2. Occurrence (Cutoff): Data occurred during the reported period.
3. Completeness: Data sets contain all activity associated with the timeframe reported. 4. Presentation & Disclosure (Classification):
The data set is presented in accordance with requirements or open government standards. 5. Reasonableness: results appear
reasonable relative to other data or trends. DOI may establish data quality activities employing a variety of data validation
(control) activities such as: Segregation of Duties – separating authorization, custody, and record keeping roles to limit
risk of fraud or error by one person; Authorization of information – review and approval by an appropriate person; Retention
of records – maintaining documentation to substantiate transactions; Supervisory reviews – analysis of actual results versus
organizational goals or plans, periodic and regular operational reviews, metrics, and other key performance indicators; Supervisory
review and approvals – Management review of reports comparing actual performance versus plans, goals, and established objectives;
Information Technology Security (general controls) – usage of passwords, access logs, etc. to ensure access restricted to
authorized personnel; and IT application controls-A variety of control activities are used in information processing. Examples
include edit checks of data entered, accounting for transactions in numerical sequences, comparing file totals with control
accounts, and controlling access to data, files and programs These principles may be applied to financial information, and
additional concepts may be formulated and applied to performance and programmatic data. Control Activities may be used to
ensure that there is a high degree of data quality and reliability. A variety of actual activities to be assessed include:
Proper Segregation of Duties, Application and general controls, and other activities deemed necessary. A senior staff member
reporting to the Assistant Secretary – Policy, Management and Budget, through the Deputy Assistant Secretary – Budget, Finance,
Performance, and Acquisition, will be responsible for the Open Government Data Quality Plan and Program. This Data Quality
Contact will coordinate the actions of the Team and support all aspects of the data quality program. The Contact will also
serve on the Department’s Open Government Core Team. The Contact will: Be the contact for external entities including OMB,
for the data quality program; Serve on the Open Government Core Team; Maintain the centralized policies, procedures, and records
for data quality; Promote high quality data that can be released to the public; Provide guidance and staff support for data
quality risk management, internal controls, reporting, and all other program aspects; Conduct an inventory of data sources
for evaluation of data quality; and Provide advice to bureaus and offices in performing aspects of the data quality program.
DOI’s Data Quality Framework for Federal Spending is expected to be submitted to OMB on April 14, 2010.
Objective(s):
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